20/02/2026
Move beyond vague Digital Product Passport assurances. These three questions will transform your board meeting discussions, revealing undeniable transparency or exposing costly illusions.
You sit there. The slide deck looks green. The roadmap seems plausible. Everyone nods. But most boards are currently being sedated by what I call "Compliance Theatre."
There is a massive, dangerous gap between having a certificate and having the operational continuity required to survive the 2026 enforcement.
Next time you are in that room, don't ask about timelines. Ask these three diagnostic questions.
1. "Can we produce the homogeneous material-level breakdown for a random SKU in under 60 minutes?"
If the answer involves waiting for a supplier to reply to an email or logging into a portal to find a PDF... you are in trouble.
→ That is not a data system. That is a glorified paper trail.
Real alignment requires machine-readable data (XML/JSON). If you cannot query the chemical composition of a specific batch instantly, you don't actually own your provenance.
2. "How does our system handle a REACH SVHC update without manual re-entry?"
The dangerous answer: "Our compliance team does a bi-annual review."
Manual review is tactical hell. It guarantees human error.
A formidable infrastructure uses data interoperability. It automatically flags every affected SKU the moment the regulation shifts. If it isn't automated, it isn't scalable.
3. "If our current DPP platform vendor went bankrupt tomorrow, who owns the unique product identifiers?"
This is the one that usually kills the mood.
If the answer is "it's all hosted on their cloud," you have traded strategic sovereignty for temporary convenience.
The EU mandates are clear. You are responsible for data continuity for 10 years. Even if your vendor disappears. If you don't have vendor-agnostic control over your data, you are building your house on rented land.
This isn't an administrative burden. It is an ecosystem restructuring.
The boards that get this will dominate. The ones that don't will find themselves with inventory they legally cannot sell.
Does your current setup survive these three questions?
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